Audit of Occupational Health and Safety Management Framework

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1 INTRODUCTION

Environment Canada’s External Audit Advisory Committee recommended to the Deputy Minister that the 2008–2009 Departmental Audit Plan, which included an audit of the occupational health and safety (OHS) management framework within Environment Canada, be completed the fiscal year ending March 31, 2009.

The content of this report reflects the verification, interviews, site visits and testing performed during the audit. This report summarizes the detailed audit observations and recommendations validated during exit briefings with management, along with an audit opinion and recommendations.

1.1 Background

Environment Canada's diversity of activities implies a considerable variety of occupational health and safety issues to consider, such as the fieldwork being done in the air, on water, on contaminated soil, under difficult meteorological conditions, or under emergency situations. The field and laboratory work also includes complex procedures. Environment Canada therefore requires an OHS program capable of addressing many exposures and requirements. The mandate of the Department to increase enforcement activities related to environmental protection has increased the number of staff performing this high-risk activity. Also, the Wildlife Enforcement Division may engage in use of force with firearms.

Environment Canada is committed to provide a safe and secure workplace for its employees. An ongoing focus on prevention in the workplace remains the best way to ensure a healthier and safer working environment, and the place to start is undoubtedly with the promotion of an evolving OHS program.

The Canada Labour Code, Part II (the Code) places requirements on federal employers, including government departments, to control OHS risks attached to work activities under their authority. Enforcement and administration of the Code is the responsibility of Human Resources and Skills Development Canada (Labour Program). Under section 122, the purpose of the Code is to prevent accidents and injury to health of employees arising out of, linked with, or occurring in the course of their employment. Environment Canada’s general and specific OHS obligations or duties, as an employer, are described in sections 124 and 125 of the Code. The Human Resources Branch’s role is to provide functional authority to the Department.

The Code has alerted senior management to their need to demonstrate due diligence as it pertains to the safety and health of departmental employees. Employers have specific duties in regards to each workplace they control and every work activity under their authority that occurs in a workplace that is beyond the employer’s control. These duties include but are not limited to information, training, instruction, supervision, providing prescribed safety material, investigating, recording and reporting all accidents, establishing a health and safety committee or policy committee, identifying specific work requirements, and carrying out monthly inspections so that every part of the workplace is inspected at least once a year.

The OHS function at Environment Canada had undergone a 1995 audit with four follow‑ups, as well as the Audit of Occupational Safety and Health at Environmental Protection Service Research Centres in 2004, which found issues. Risk areas found in the most recent audit include incomplete documentation, unaddressed training needs and lack of monitoring.

In the context of a constant evolution of Environment Canada’s OHS program and its related commitments, obtaining a regular independent and impartial outlook of the activity to date is important. This audit was required because a long time had passed since the last audit, and because the organizational needed to continue improving the OHS program. The audit ascertains the current state of the OHS program at a departmental level, assesses the implementation of the 2004 recommendation, and provides valuable guidelines to further improve the Department’s OHS program reliability.

1.2 Objective(s) and Scope

The primary objectives of the audit were to

The scope of the audit was Department-wide, and included all Environment Canada facilities in the regional offices, including the regional Storm Prediction Centres; Canadian Aviation Meteorological Centres and the Canadian Meteorological Centre; research institutes and laboratories; and the Environment and Wildlife Enforcement teams. The temporal scope of the audit included activities from April 1, 2007 to February 15, 2009.

1.3 Methodology

This audit was conducted in two phases:

Due to the specialized nature of the subject matter, the conduct of this audit was performed by a team of OHS specialists from AMEC Earth and Environmental, working jointly with the Audit and Evaluation Branch (AEB) to meet the technical and management requirements of this project.

A master schedule of site visits and interviews was maintained. All site visits concluded with exit interviews and finding reports that have been provided to and reviewed by program management and AEB. Detailed observations have been presented to the Director General – Strategic Planning and Corporate Programs, Human Resources Branch (HRB); and the Director General, Assets, Contracting and Environmental Management, Finance and Corporate Branch (FCB). Interview notes, finding reports and detailed observations provided the evidence to support the findings, recommendations and conclusions in this report.

A list of interviewees is included in Annex 1.

1.4 Audit Criteria

Primary audit criteria were the requirements of the Code. The applicable sections of the Code and the sections that were used as the criteria for the audit are shown in Annex 2.

Secondary audit criteria included the following OHS management system standards and guidelines:

1.5 Audit Limitations

There were no significant limitations that impacted the completion of the audit.

1.6 Risk Assessment

The initial risk assessment of the existing OHS management framework was completed using guidance provided in ISO 9004:2000 Quality Management Systems – Guidelines for Performance Improvement. This assessment model is based on several widely recognized and widely used models for national and regional quality awards, such as the Baldrige Award in the United States and the Canada Awards for Excellence. The auditors used a maturity index with four levels (Innocence-to-Excellence) to assess the existing management framework elements.

Phase I concluded that the roles and responsibilities are not clearly and consistently defined and communicated for all levels of the OHS function. While regional OHS managers are aware of the general requirements of the Code, they may not be fully aware of their direct responsibilities for ensuring the organization can demonstrate compliance. The OHS training that is provided may not be sustainable, i.e., retained by employees for a sufficient period of time.

The audit team then selected a sample of regions, sites and operational activities to be audited during Phase 2 of the Audit. The sample was selected based on professional judgment and the risk assessment performed in Phase I, taking into account the following:

This ranking is based on the nature and frequency of higher‑risk activities undertaken in each of these branches, including working over water, working with hazardous materials, working with firearms, helicopter work and working in isolated areas.

1.7 Statement of Assurance

This audit has been conducted in accordance with the International Standards for the Professional Practice of Internal Auditing and the Policy on Internal Audit of the Treasury Board of Canada.

The audit was also conducted in accordance with these additional auditing and assurance standards:

Along with our professional judgment, sufficient and appropriate audit procedures have been conducted and evidence gathered to support the accuracy of the conclusions reached and contained in this report. The conclusions are based on a comparison of the situations, as they existed at the time, against the audit criteria.

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